The Review · Case Index

California employment case index

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2 cases

California Federal Savings & Loan Assn. v. Guerra: Pregnancy-Leave Statute Upheld — the “Floor, Not a Ceiling”

January 13, 1987
When Lillian Garland returned from pregnancy disability leave to find her receptionist job filled, California’s guarantee of leave and reinstatement collided with her employer’s theory that Title VII forbade treating pregnancy “better” than other disabilities. The Supreme Court sided with California: the Pregnancy Discrimination Act is a floor beneath which pregnancy benefits may not drop, not a ceiling above which states may not rise — and employers can always comply with both laws by leveling benefits up. Guerra remains the constitutional foundation of the PDLL and of every California pregnancy protection built since.